S. Janardhana v. Shri Anil Kumar Singhal & 2 Others, 2026

In that earlier writ proceeding, the High Court had directed the respondents to implement an order dated 25 September 2018 passed by the Tribunal in O.A. No. 2044 of 2018, preferably within three months from receipt of the High Court's order. 

When the contempt matter came before the Division Bench, the Court specifically asked when the three-month period had expired. The petitioner's counsel acknowledged that the period had expired long before the contempt petition was filed and that the petition was not filed within the one-year limitation period prescribed by Section 20 of the Contempt of Courts Act, 1971. 

The petitioner nevertheless argued that the alleged non-compliance constituted a continuing cause of action/continuing wrong, and therefore the one-year limitation should not prevent the contempt proceedings.

The Court rejected that contention. It also considered the fact that the Tribunal's 2018 order had subsequently been challenged in W.P. No. 3322 of 2024, which was dismissed on 8 February 2024. The High Court held that this subsequent litigation did not extend the limitation period because the earlier High Court order of 22 July 2022 had not been stayed or kept in abeyance. 

The Court held that the earlier order had specifically directed compliance within a period of three months. Once that period expired without compliance, the limitation period under Section 20 of the Contempt of Courts Act, 1971 began to run.

The Court was not persuaded by the petitioner's argument that the cause of action was continuing. It emphasized that merely describing a breach as a “continuing wrong” cannot automatically overcome the statutory limitation period. 

The Bench also noted that the petitioner had not pleaded facts establishing a continuing cause of action or disclosed grounds on which exemption from limitation could be sought. 

The subsequent challenge to the Tribunal's order did not assist the petitioner because the relevant High Court order of 22 July 2022 had never been shown to have been stayed or kept in abeyance. 

The petitioner attempted to characterize the respondents' alleged non-compliance as a continuing wrong. The Court relied upon the Supreme Court's guidance that courts must be cautious about allowing stale contempt claims to be presented years later under the label of continuing breach.

The Court noted that the petitioner had not specifically pleaded facts establishing a continuing cause of action or grounds for exemption from limitation. Thus, simply making a submission during arguments was insufficient.

The judgment draws an important distinction between exemption from limitation and ordinary condonation of delay. The Supreme Court authorities cited by the Bench recognize that, in an appropriate case, grounds for exemption may be available, but ordinary Section 5 condonation principles cannot simply be invoked to bypass Section 20.

The fact that the Tribunal's order was later challenged did not revive the limitation period. The decisive order for the contempt claim was the High Court's 22 July 2022 direction, which itself provided three months for compliance. There was also no material showing that this order had been stayed. 

The judgment reinforces procedural discipline in civil contempt proceedings. It indicates that a person alleging deliberate non-compliance with a court order should act within the statutory period and should not rely merely on the continuing nature of an alleged breach to revive an otherwise time-barred contempt claim.